- 21 - 6, 1985). Thus, section 274(d) overrides Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930), which allows the Court, in some circumstances, to estimate a deductible expense. See Sanford v. Commissioner, 50 T.C. 823, 827 (1968), affd. per curiam 412 F.2d 201 (2d Cir. 1969); sec. 1.274-5T(a), Temporary Income Tax Regs., supra. Although petitioner offered into evidence numerous receipts in support of his travel, meals, and entertainment expenses, he did not provide the additional documentation necessary to substantiate these expenses. In particular, the receipts did not show the business purpose behind the trips or meals. In short, there was no documentation or rationale behind such expenses other than petitioner’s unsupported testimony that the Court declines to accept. Sec. 1.274-5T(a), Temporary Income Tax Regs., supra. Respondent is sustained on this issue. On a separate Schedule C of petitioner’s 2000 income tax return, petitioner claimed a deduction for expenses relating to another activity called “Frexie”. This was the name petitioner ascribed to his purchase of the right to use a luxury suite at Minute Maid Park in Houston, Texas, the home field for the Houston Astros major league baseball team, for a 3-year period for $250,000. The Frexie activity involved the selling or letting by petitioner of the use of the suite during Houston Astros baseball games. In exchange for a commitment to purchasePage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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